DOW - Alliance Annual Report - April 10, 2006

ALLIANCE ANNUAL REPORT
Occupational Safety and Health Administration
and
The Dow Chemical Company (Dow)
April 10, 2006

  1. Alliance Background

    Date Signed

    January 13, 2003

    Date Renewed

    May 26, 2004

    Evaluation Period

    January 13, 2005 – January 12, 2006

    Overview

    The OSHA and The Dow Chemical Company Alliance focuses on using OSHA's and Dow's collective expertise to further enhance a culture of prevention while sharing proven practices and technical knowledge in the areas of, but not limited to, process safety management (PSM) and ergonomics.

    Implementation Team Members

    OSHA:

    Brett Besser
    Salt Lake Technical Center (SLTC)
    Mark Briggs
    Region VI
    John Bugno
    Directorate of Standards and Guidance (DSG)
    Cathy Cronin
    Office of Training and Education
    Kevin Cummins
    SLTC
    Lee Anne Jillings
    Office of Outreach Services and Alliances (OOSA)
    Todd Jordan
    SLTC
    David O'Connor
    DSG
    Lisa Ramber
    OOSA
    Beth Sherfy
    OOSA

    Dow:

    Joe Amos
    Regulatory Affairs Leader, West Virginia
    John Dizor
    Personal Safety Expertise Leader
    Rick Holmes
    Industrial Hygiene Expertise Leader
    George King
    Process Safety Technical Leader
    Dale Louda
    Washington Office Advocacy Leader
    Tim Overton
    Chief Process Safety Engineer
    Jeannine Sohayda
    EH&S Public Affairs
    Mark Spence
    H&S Regulatory Affairs

  2. Implementation Team Meetings

    February 15, 2005
    Alliance Program Hazard Communication Roundtable, Washington, DC
    March 22, 2005
    Implementation Team Meeting, Teleconference
    May 2, 2005
    Case Study Development Meeting, Teleconference
    July 19, 2005
    Implementation Team Meeting, Teleconference
    July 26, 2005
    Case Study Development Meeting, Teleconference
    August 1, 2005
    Alliance Program Workgroup Promoting the Globally Harmonized System for Classification and Labeling of Chemicals Meeting, Washington, DC
    September 28, 2005
    PSM Seminar for Region III Planning Meeting, Teleconference
    October 21, 2005
    Implementation Team Meeting, Teleconference

  3. Results

    1. Events and Products

      Outreach and Communication Goals

      Develop and disseminate information on effective elements of safety and health programs at conferences, events, or through print and electronic media.

      Products

      OSHA Electronic Assistance Tools

      Through the Alliance, Dow representatives continue to provide expertise to review, maintain and update many of OSHA's Safety and Health Topics pages as well as OSHA's Ammonia Refrigeration eTool.

      OSHA Safety and Health Topics Pages

      The following representatives from Dow serve on the editorial boards of the following 8 OSHA Safety and Health Topics pages:

      • Ammonia Refrigeration

        • Don Jones, PE, CSP, Plaquemine, LA

      • Chemical Reactivity Hazards

        • Kenan Stevick, Midland, MI

      • Emergency Preparedness and Response

        • Susan Ripple, MS, CIH, Global industrial Hygiene Expertise Center; Midland, MI

      • Health Care Facilities

        • Susan Ripple, MS, CIH, Global industrial Hygiene Expertise Center; Midland, MI

      • Isocyanates
        • John Cikalo, Global Industrial Hygiene Expertise Center, Midland, MI

        • Mark Spence, Global Industrial Hygiene Expertise Center, Midland, MI

      • Process Safety Management

        • George King, Process Safety Technology Center, Freeport, TX

      • Radiation: Radiological Dispersal Devices/Dirty Bombs

        • Susan Ripple, MS, CIH, Global industrial Hygiene Expertise Center; Midland, MI

      OSHA eTools

      Representatives of the OSHA and Dow Alliance serve on the editorial board of OSHA's Ammonia Refrigeration eTool:

      • Randy Estep, Houston, TX
      • Don Jones, Plaquemine, LA

      • Mark Spence, Midland, MI

      OSHA and Dow Alliance Web Page

      OSHA continues to update the OSHA and Dow Alliance Web page on the Agency's Web site. The Web page features links to the Alliance agreement and related documents, information on activities and events, and milestones and successes. During the evaluation period, the Web page was updated to include information about Dow's PSM Seminar for Region III staff, which was November 16-17, 2005, in South Charleston, West Virginia and a link to the OSHA and Dow Alliance case study, Motor Vehicle Accident Case Study: "The Dow Chemical Company's Use of the 'Six Sigma' Methodology. For information on the number of visits to the OSHA and Dow Alliance Web page, please see the Alliance Program Reach table.

      Print and Electronic Media

      Articles on the OSHA and Dow Alliance, and products developed through it, have appeared in print and online publications, including: BNA Conference Report and OSHA's Alliance Quarterly Review. For more information on the articles, please see the Alliance Program Reach table on page 7.

      Events

      National Safety Council's Congress and Expo, Orlando, Florida, September 22, 2005

      On September 22, 2005, Mark Spence participated on the panel entitled, "Successes with OSHA's Ergonomic Alliances," at National Safety Council's Congress and Expo in Orlando, Florida. Mr. Spence discussed the ergonomics case study, "The Dow Chemical Company's Use of the 'Six Sigma' Methodology", which describes the Six Sigma methodology and how Dow used it to successfully address ergonomics hazards in the company's design and construction division. Other panelists included Paula White, Director, Directorate of Cooperative and State Programs, USDOL-OSHA and a representative from the OSHA and Graphic Arts Coalition Alliance.

      • Gain a better understanding of the diversity of methods and processes for addressing health and safety challenges in the workplace. Develop ways for communicating effective approaches including cross-training, job aids, and usability studies.

      Events

      Chemical Reactivity Hazard Management Seminar, Atlanta, Georgia, September 26, 2005

      On September 26, 2005, Cal Towns, Process Safety Advisor for The Dow Chemical Company's Global Chlorinated Organics Business, served as a speaker at the workshop, "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," held during the Chlorine Institute's 2005 Fall Meeting in Atlanta, Georgia. The workshop, organized by the OSHA and Chemical Reactivity Hazards Management Alliance, provided information on chemical reactivity hazards and strategies and tools for identifying and preventing reactivity accidents at manufacturing facilities. Approximately 20 representatives from small chemical manufacturers, warehouse facilities, distributors and batch processors attended the workshop.

      Process Safety Management Workshop, South Charleston, West Virginia, November 16-17, 2005

      Through the Alliance, in 2003 Dow and OSHA developed a workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach," discussing the various aspects of the PSM standard, including process safety information, process hazard analysis procedures and management of change, and how Dow Chemical Company implements the PSM Standard in its workplaces. The Alliance hosted another session of the workshop on November 16-17, 2005, at The Dow Chemical Company's West Virginia, Operations, in South Charleston, West Virginia. The workshop was attended by 30 OSHA staff from OSHA's National and Region III Offices and West Virginia Consultation Project. It also included time for attendees to tour Dow's facilities. The PSM workshop built on the success of two previous workshops hosted by the OSHA and Dow Alliance for OSHA staff from Regions IV, V, and VI.

      • Provide OSHA with opportunities, where appropriate and agreeable to both parties, to experience hands-on information sharing in Dow's facilities to "test run" ideas and to gain a better understanding for real world impact and applications.

        During this evaluation period, no products or resources have been developed to meet this Alliance goal.

      Promoting the National Dialogue on Workplace Safety and Health Goals

      • Encourage Dow worksites, and personnel to act as industry liaisons and resources for OSHA's cooperative programs and Compliance Assistance Specialists.

        During this evaluation period, no products or resources were developed to meet this Alliance goal.

      • Seek opportunities to participate in stakeholder groups and other forums for providing input into the development of safety and health standards and guidance for the chemical industry.

      Events

      Alliance Program Hazard Communication Roundtable, Washington, DC, February 15, 2005

      Matt Sczepanski, Mark Spence and Imogene Treble attended the Alliance Program Hazard Communication Roundtable, which was February 15, 2005, in Washington, DC. The Roundtable brought together 18 Alliance Program participants to identify hazard communication compliance assistance projects and activities that they could work on together. The Promoting the Globally Harmonized System for the Classification and Labeling of Chemicals (GHS) Workgroup was established at the Roundtable meeting.

      • Promoting the GHS Workgroup

        August 1, 2005, Washington, DC – Mark Spence attended the Promoting the GHS Workgroup meeting. The Workgroup identified a number of compliance assistance tools that it could develop to support OSHA's plans to adopt the GHS as part of its Hazard Communication Standard.

      • Identify and enhance methods and processes to evaluate the effectiveness of the Alliance and to encourage the continuous improvement of workplace health and safety practices and communication.

        During this evaluation period, no products or resources were developed to meet this Alliance goal.

      • Share information on proven practices of Dow worksites with others in industry through outreach directly by Dow and also through OSHA.

      Products

      "Motor Vehicle Accident Case Study: The Dow Chemical Company's Use of the 'Six Sigma' Methodology"

      Through the Alliance Program, Dow worked with OSHA to develop a motor vehicle case study, "The Dow Chemical Company's Use of the 'Six Sigma' Methodology," which was posted on OSHA's Web site in December 2005. ("Six Sigma" is a process-oriented approach to problem solving that emphasizes a four-step improvement methodology of measure, analyze, improve and control). The motor vehicle accident case study discusses how Dow applied the "Six Sigma" management system strategy to successfully reduce motor vehicle accidents in the company's Hydrocarbons and Energy business unit. The motor vehicle accident case study has been added to a number of OSHA's Web pages, including the OSHA and Dow Alliance page, Compliance Assistance page and Motor Vehicle Safety and Health Topics page.

      • Work together to develop new approaches and practices to address health and safety risks.

        During this evaluation period, no products or resources have been developed to meet this Alliance goal.

      • Share data supporting the solutions to ergonomic hazards developed by Dow, as well as examples of hazard recognition strategies and analytical tools with OSHA and others in the industry to encourage wide implementation. Promote their implementation through print and/or electronic media, promotion at conferences, or other means of reaching out to others in industry.

        During this evaluation period, no products or resources have been developed to meet this Alliance goal.

      Other Issues

      Hurricane Katrina Response

      Through the Alliance Program, Dow offered to donate personal protective equipment (PPE) for OSHA to use as part of its Hurricane Katrina and Rita response efforts. The PPE, which will include hard hats, gloves and protective vests, will be used by OSHA's Region IV and VI Offices. OSHA and Dow are working together to coordinate Dow's PPE donation in compliance with the Department of Labor's requirements for donations from nongovernmental entities.

    2. Executive Summary

      During the 2005-2006 evaluation period and final year of the first Alliance renewal agreement, OSHA and Dow worked together to further enhance a culture of prevention while sharing proven practices and technical knowledge in the areas of, but not limited to, PSM and ergonomics. Through the Alliance Program, OSHA and Dow developed several compliance assistance resources with information about the Alliance and ergonomics. The OSHA and Dow Web site on OSHA's Web page provides links to the Alliance agreement, related documents, activities and events, and milestones and successes. Representatives from Dow serve as members of a number of OSHA's Safety and Health Topics page's editorial boards, including Ammonia Refrigeration, Chemical Reactivity, Health Care Facilities and PSM. Dow representatives also are members of OSHA's Ammonia Refrigeration eTool's editorial board, which OSHA developed with input from the Dow and the American Meat Institute Alliances in 2004.

      As part of the OSHA and Dow Alliance's outreach efforts, Mark Spence participated on a panel entitled, "Successes with OSHA's Ergonomic Alliances," at the National Safety Council's Congress and Expo on September 22, 2006, in Orlando, Florida. Mr. Spence discussed the "Ergonomics Case Study: The Dow Chemical Company's Use of the Six Sigma Methodology." Other panelists included Paula White, Director, Directorate of Cooperative and State Programs, USDOL-OSHA and a representative from the OSHA and Graphic Arts Coalition Alliance.

      The OSHA and Dow Alliance also developed a "Motor Vehicle Accident Case Study: The Dow Chemical Company's Use of Six Sigma Methodology," which was posted on OSHA's Web site in December 2005. The case study describes the Six Sigma methodology and how Dow used it to successfully reduce motor vehicle accidents in the company's Hydrocarbons and Energy business unit.

      Through the Alliance, Dow and OSHA developed a workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach," discussing the various aspects of the PSM standard. The Alliance hosted another session of the seminar on November 16-17, 2005, at the Dow Chemical Company's West Virginia, Operations, in South Charleston, West Virginia. It was attended by 30 OSHA staff from OSHA's National and Region III Offices and West Virginia Consultation Project and included a tour Dow's facilities in South Charleston, West Virginia. The PSM workshop built on the success of two previous workshops hosted by the Alliance on October 13-14, 2004, in Plaquemine, Louisiana and September 16, 2003, in Arlington Heights, Illinois.

      In addition, on September 26, 2005, Cal Towns, Process Safety Advisor for The Dow Chemical Company's Global Chlorinated Organics Business, served as speaker for the workshop, "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," during the Chlorine Institute's 2005 Fall Meeting in Atlanta, Georgia. The workshop, organized by the OSHA and Chemical Reactivity Hazards Management Alliance, provided information on chemical reactivity hazards. Approximately 20 representatives from small chemical manufacturers, warehouse facilities, distributors and batch processors attended the workshop.

      The Alliance implementation team members also worked with other Alliance Program participants throughout the year. Dow participated in the Alliance Program Hazard Communication Roundtable in Washington, DC, on February 15, 2005. Dow also attended the Alliance Program's Promoting the GHS Workgroup meeting on August 1, 2005.

    3. Alliance Program Reach

      Type of Activity (Conference, Training, Print and Electronic Distribution, etc.) Number of Individuals Reached or Trained
      OSHA and The Dow Chemical Company Web page on OSHA's Web site 4,649
      Dow representative serve on eight of OSHA's Safety and Health Topics pages' editorial boards:
      • Ammonia Refrigeration
      • Chemical Reactivity Hazards
      • Emergency Preparedness and Response
      • Health Care Facilities
      • Isocyanates
      • Motor Vehicle Safety
      • Process Safety Management
      • Radiation: Radiological Dispersal Devices/Dirty Bombs
      		Data Not Available
      OSHA's Ammonia Refrigeration eTool Data Not Available
      February 15, 2005: Alliance Program Hazard Communication Roundtable, Washington, DC
      Dow Participated      		 18
      March 2005: "Hazcom Roundtable Address MSDSs, Compliance Assistance Issues," Alliance Quarterly Review 300
      June 16, 2005: "OSHA Alliance Successes Cited by Agency Official at Safety Conference," BNA Conference Report Data Not Available
      August 1, 2005: Alliance Program's Promoting the Globally Harmonized System for Classification and Labeling of Chemicals (GHS) Workgroup Meeting, Washington, DC 12
      September 22, 2005: "Successes with OSHA's Ergonomic Alliances," National Safety Council's Congress and Expo, Orlando, Florida
      Speakers:
      Mark Spence, Dow
      Paula White, OSHA      		 50
      September 26, 2005: "Managing Chemical Reactivity Hazards: A Workshop for Non-Chemists," Chlorine Institute's 2005, Fall Meeting, Atlanta, Georgia
      Speaker: Cal Towns, Dow      		 20
      November 16-17, 2005: Process Safety Management Workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach," South Charleston, West Virginia
      Dow Speakers:
      Andy Altman
      Joe Amos
      Steve Barron
      Jeff Blatt
      Brenda Brown
      Tami Clark
      Mike Cunningham
      Jeff Goad
      Don Hanks
      George King
      Clark McCoy
      Brenda Meyers
      Kim Smith
      Dave Veazey
      Giles Watson
      OSHA Speakers:
      Stan Elliott, OSHA
      Elizabeth Sherfy, OSHA      		 30
      December 2005: "Chemical Reactivity Hazards Workshop a Tutorial on Hazards Recognition, Possible Safety," Alliance Quarterly Review 300
      December 2005: "Workshop Emphasizes Benefits of Process Safety Management at Dow," Alliance Quarterly Review 300
      December 2005: "The Motor Vehicle Accident Case Study: The Dow Chemical Company's Use of Six Sigma Methodology," Data Not Available
      TOTAL 5,679

  4. Upcoming Milestones

    During the Alliance's next year, OSHA and Dow will renew the Alliance agreement and continue to promote awareness of the Alliance Program and workplace safety and health issues, including ergonomics and PSM. The Alliance implementation team members will also continue to maintain and update the OSHA and Dow Alliance Web page on OSHA's Web site. In addition, Dow representatives will review and provide OSHA with information for the Agency's Ammonia Refrigeration eTool and Safety and Health Topics pages.

    OSHA and Dow will also work together to finalize a third case study on fleet safety, which will be posted on OSHA's Web site. In addition, the OSHA and Dow Alliance will develop a short PowerPoint® presentation for use with the motor vehicle and fleet safety case studies. The slides will be available on OSHA's Web site for speakers who want to use Dow's case studies in a presentation. The OSHA and Dow Alliance will also develop new topics for developing additional case studies.

    In addition, Mark Spence offered to serve on a proposed workshop panel at the 2006 National Safety Council's Congress and Expo in San Diego, California. The proposed panel will highlight the many case studies developed through the Alliance Program, and include representatives from the Graphic Arts Coalition and The Steel Group Alliances.

    The OSHA and Dow Alliance implementation team will identify Regional Offices within OSHA that would like to attend Dow's workshop, "OSHA's Process Safety Management (PSM) Standard: The Dow Approach." The workshop discusses the various aspects of the PSM standard.

    Dow will finalize its donation of personal protective equipment (PPE) for OSHA to use as part of its Hurricane Katrina response efforts. The PPE, which will include hard hats, gloves and protective vests, will be used by OSHA's Region IV and VI Offices. OSHA and Dow are working together to coordinate Dow's donation in compliance with the Department of Labor's requirements for donations from nongovernmental entities.

Report prepared by: Elizabeth Sherfy, Alliance Coordinator, Office of Outreach Services and Alliances, April 10, 2006.